If your program contains duplicate paragraph names, both COBOL systems
will resolve references to the duplicate paragraph names in the same way,
provided the duplicate paragraph names are only referenced from within
the sections in which they are declared. If, however, you reference a
duplicate paragraph name from a different section to the one it is
declared in, the RM/COBOL system will assume that the reference is to the
next declaration of the duplicate paragraph name, whereas this COBOL
system will give an error when you are producing intermediate code.

Solution

To ensure that references to duplicate paragraph names are correctly
resolved, you must qualify a reference to a duplicate paragraph name by
adding the section name in which it is declared.

the RM/COBOL system will resolve the reference to para-2 in the PERFORM
statement by using the declaration of para-2 in the sect-1 SECTION. Under
this COBOL system, however, you must qualify the reference to the
duplicate paragraph name in your source code by using the PERFORM para-2
OF sect-1 statement.

this is from rm/cobol but found that it works in all type of cobol compilers